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should be denied because Goldman has already forfeited to itself approximately one million dollars of options and restricted stock non-cash compensation it paid to him as a director. Thus, it has already obtained well over 75 per cent of Gupta's total director compensation," the motion said.

Gupta added that Goldman has merely submitted bulk bills with no effort to organise them in categories, or otherwise segregate what is recoverable from what is not.

"Goldman has not even begun to satisfy its burden of showing the fees are recoverable, reason alone to refuse to order restitution of any legal fees, but even more so because the failure to provide detailed support for the request renders the determination of any restitution unduly complex," the papers said.

Gupta is appealing his conviction on insider trading charges and earlier this month was granted permission to stay out of prison on bail pending appeal.

The former McKinsey head was slapped a USD five million fine and sentenced to two years' imprisonment.

His jail term was to begin on January 8 next year but he would now remain free on a USD 10 million bond till the appeals court rules next year on his request to overturn his conviction.